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Markets and Securities Services | Issue 46
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Data and data protection
Linked to the above segment on
increased disclosure and data come
associated risks concerning data
protection. For example, under the
transaction reporting requirements
for “natural” persons, the Legal Entity
Identifier (LEI) is replaced with a natural
identifier, e.g. a passport, along with
other increased information disclosure.
Q15 Have you ensured that you are
comfortable that any outsource providers
are also able to comply with these same
data protection requirements?
While a majority (67%) of asset managers
confirm they are comfortable that any chosen
outsourced provider will also be able to
comply with the data protection requirements,
the remainder advise it is either too soon to
tell or that they weren’t comfortable.
Q16 Will the extensive data demands arising
from legislation such as MiFID II/MiFIR result
in a greater level of outsourcing by your firm?
Firms are split on whether a greater level
of outsourcing will be required as a result
of the extensive data demands arising
from the MIFID II/MiFIR legislation. 56%
of respondents agree that it will, while the
remainder do not.
Target market/appropriateness regime
Under product governance rules and the
appropriateness regime, firms need to
ensure that “target markets” are aligned
with distribution strategies.
Product governance refers to the systems
and controls firms have in place to design,
approve, market and manage products
throughout their lifecycle to ensure they
meet legal and regulatory requirements.
Good product governance should result in
products that:
i. Meet the needs of one or more
identifiable target markets.
ii. Are sold to clients in the target markets
by appropriate distribution channels.
iii. And deliver improved consumer outcomes.
Under product
governance rules and
the appropriateness
regime, firms need
to ensure that
“target markets”
are aligned with
distribution strategies.